On the record

Background

On January 30, 2018, five University of Sydney researchers, under the auspices of their Community Project Partner, Community Mental Health Australia (CMHA), and funded by the University of Sydney Policy Lab, released a paper entitled “Mind the Gap: The National Disability Insurance Scheme and psychosocial disability” (the Report).

The underlying factual premise of the Report is that “current participation” in the National Disability Insurance Scheme (NDIS) “of people with a primary psychosocial disability is low and indicates multiple difficulties in the implementation of the Scheme”. The researchers stated that they engaged with “58 organisations from each state and territory” to identify gaps and propose solutions to why a perceived gap had emerged for people with a psychosocial disability. They also stated that the views expressed in the Report were “substantially validated by an independent academic review of related publications, reviews and reports”.

NDIA response

The National Disability Insurance Agency (NDIA) is committed to delivering a superior outcome for NDIS participants with a psychosocial disability. The NDIA also recognises that the NDIS is a major social reform that is creating major opportunities for but also causing significant uncertainty for people with disability, both those eligible for the NDIS and those who are not. In that context, the NDIA pays tribute to and applauds the organisations on the ground that are committed to supporting people with a psychosocial disability. They play a critical role within the broader disability ecosystem. The NDIA is clearly of the view that these organisations need to be supported as the adjustment to the NDIS occurs. More specifically, the NDIA is supportive of continuity of support arrangements and an appropriate level of mainstream services for those people not eligible for the NDIS.

Notwithstanding that commitment, the NDIA takes issue with many statements in the “Mind the Gap” Report. The NDIA is disappointed that academics from an institution as respected as Sydney University have produced an unbalanced report based on factually incorrect data that does not recognise work that is already underway by the NDIA.

The NDIA has reached that conclusion for three fundamental reasons.

1. The facts that underpin the approach taken in the Report are inaccurate or have been misrepresented.

- Contrary to the assertion in the Report, in 2011 the Productivity Commission, not the NDIA, developed the baseline number of people with a psychosocial disability who would enter the NDIS. While the NDIA has adjusted that number for the intervening population increase (bringing the relevant number to 64,000), the Productivity Commission’s 2017 report on NDIS Costs, confirmed that this estimate is appropriate and consistent with the Commission’s own 2011 modelling.

- The assertion that “only 6.4 percent of Scheme participants have a primary psychosocial disability which is less than half the expected numbers” misrepresents the facts. Participants are still phasing into the Scheme and the current proportion of participants in each disability group is not reflective of the percent expected when the Scheme is fully rolled out. Phasing schedules agreed between the Commonwealth and the States and Territories guide the NDIA’s progressive roll out of the Scheme. This applies both to geographies and age groups. Only by looking at sites such as the Hunter (NSW), Barwon (Victoria) and the ACT where the roll-out is complete can an accurate assessment be made. Data from those sites indicates that at 30 September 2017 the percent of individuals with a psychosocial disability who are currently eligible is 12.7 percent; 13.8 percent; and 13.0 percent, very close to the Productivity Commission’s original projection of 13.9 percent. In other words, the proportion of people with a psychosocial disability is consistent with the Productivity Commission’s estimate in geographies where a full roll out has occurred, thereby undermining the fundamental premise of the “Mind the Gap” Report.

- The comment that “a great many people had been assessed as ineligible even if they had a disability support pension” shows a lack of understanding of the approach for implementing the NDIS and is a misrepresentation of the facts. As at 30 September 2017, around 700,000 people aged 16-64 years, had access to a Disability Support Pension (DSP), of which 245,700 (35 percent) had a primary disability of “Psychological/Psychiatric”. This higher number than the 64,000 expected to enter the NDIS with a psychosocial disability reflects the fact that the criteria for accessing the DSP is broader than that for the NDIS. The NDIS was never intended to apply to all people on a DSP. This conclusion by the researchers is inaccurate and disappointing.

- The assessment that people with a psychosocial disability are “missing out” because “to date, 81.4 percent of people with psychosocial disability who requested access were accepted into the Scheme compared to 97 percent for people with cerebral palsy, autism or intellectual disability” is incorrect. The difference reflects the fact that people with a psychosocial disability are likely to be older and less likely to be in receipt of a State/Territory or Commonwealth defined programme, which have higher rates of eligibility. In other words, it reflects the way the Scheme is being rolled out in different jurisdictions. It is therefore a misrepresentation of the facts.

- There is no validity to the statement “that people’s plans were almost invariably reduced at review”. Based on internal NDIA data, it can be confirmed that this assertion is factually inaccurate.

2. The report does not use a transparent and balanced set of sources.

- The researchers did not consult with the NDIA, even though extensive comments are made about the NDIA. If their facts had been checked with the NDIA, the broadly accepted academic commitment to factual accuracy and objectivity might have been more readily upheld.

- The sample of organisations cited as being “Contributing Stakeholder Organisations and Programs” is not representative of the proportion of NDIS participants with psychosocial disabilities. Analysis by the NDIA shows that the geographic spread of organisations that contributed is not matched to the proportion of participants entering the Scheme; to the number of participants by State and Territory with a psychosocial disability; or even to relative population size. As one example, this can be seen with the percent of representatives consulted from the Northern Territory. To date, 0.3 percent of participants with a psychosocial disability come from the Northern Territory, but 9 percent of the Contributing Organisations were from the Northern Territory. This is not in any way to underestimate the importance of the Northern Territory to the Scheme or the importance of listening to indigenous voices, to which the NDIA is fully committed. It merely reflects a fundamental view that academic sample sizes should typically be proportional to the profile of the subject under assessment.

- The researchers stated desire “to create a ‘safe’ environment for stakeholders” results in the researchers themselves acknowledging that it is not possible to attribute views to “individuals or organisations”. While the NDIA understands this perspective, it is not necessarily consistent with the transparent standards to which academics typically aspire.

- The methodology for collecting source data is not revealed, contrary to normal academic practice.

- The researchers state that they validated their work through an “independent academic review of related publications”. While the report contains thirty footnotes, over one-third of those are submissions to parliamentary bodies by Community Mental Health Australia or closely related advocacy bodies. It is, therefore, difficult to validate the claim of an “independent academic review” by the researchers, as unusually for an academic work, no bibliography is included.

3. The report fails to acknowledge that almost all issues raised in the Report are already being addressed by the NDIA.

- The thirty pages of challenges and solutions posed to the NDIA as outlined in the “Mind the Gap” Report provides virtually no acknowledgement of the work currently underway by the NDIA to address these known challenges. Indeed, the only acknowledgement is in one footnote in relation to telephone planning. It is disappointing and curious that this has occurred despite the NDIA’s widespread and public communication around the initiatives that are underway.

- The work being undertaken by the NDIA was publicly known well in advance of the publication of the “Mind the Gap” Report in January 2018. It is disappointing that researchers from the highly respected Sydney University should not acknowledge the work that is underway. More specifically, some of the NDIA initiatives that relate specifically to the “Mind the Gap” Report are as follows:

- The NDIA initiated a review of the NDIS Participant and Provider Pathways in April 2017, with over 300 participants and providers being involved in that review.

- In October 2017, the NDIA announced the revised Pathways, with representatives from Community Mental Health Australia being given differential access to the results of that work.

- Since October 2017, as publicly announced, the NDIA has taken steps to develop a tailored pathway for people with psychosocial disability. The NDIA has partnered with Mental Health Australia to deliver four of these workshops, with its being anticipated that detailed work on the proposed revised tailored pathway will be completed by March 2018. The extent and nature of that work could easily have been ascertained by consultation with the NDIA or peak mental health groups. The “Mind the Gap” Report makes no reference to this work.

- Since October 2017, as publicly announced, the NDIA has taken steps to tailor the participant pathway for people in Aboriginal and Torres Strait Islander communities. This work is being undertaken through seven workshops engaging participants, providers, peak bodies and advocacy organisations through February and March. It is expected that the tailored pathway for participants in Aboriginal and Torres Strait Islander communities will be completed by end of March. Again, this is publicly available information.

- An Independent Pricing Review was initiated by the Board of the NDIA in June 2017. McKinsey delivered that report in late December 2017. It is now under consideration by the NDIA Board and management, with a commitment to release the report and the NDIA’s response by mid-March 2018 at the latest. This information is publicly known, extensive consultation has occurred, yet it is not acknowledged in the “Mind the Gap” Report despite extensive commentary on NDIA pricing.

Conclusion

The “Mind the Gap” Report was published under the name of the University of Sydney, thereby lending credence to this report being a serious academic study.

The NDIA proactively engages with individuals from the sector and, if invited, would have been more than willing in advance to discuss the Report with the academics undertaking the work.

The researchers did not choose to engage with the NDIA, nor does the Report acknowledge the work that the NDIA currently has underway. Moreover, many of the facts used in the Report are inaccurate, taken out of context and misrepresent the situation in relation to the status of people with a psychosocial disability.

As a result, the NDIA is concerned that the anxieties of people with a psychosocial disability might be exacerbated by this Report.

For this reason, the NDIA has released this paper to correct the record in relation to the “Mind the Gap” Report.